The IRS was asked to rule on whether particular rights associated with a marital trust set up via an antenuptial agreement was a contingency under I.R.C. Sec. 2056(b)(1) that negated the martial deduction for distributions to the trust. The IRS determined that the right of the spouse to elect an amount to fund the marital trust was not a contingency because of trust language that gave the spouse beneficial enjoyment of marital trust assets. IRS also determined that the spouse had a qualifying income interest for life in the LLC units. Priv. Ltr. Rul. 201410011 (Nov. 9, 2013).